Action for damages by garage owner P against D, the
administrator of the estate of S, who was burned to death in
a fire in P's garage. P's complaint claims that S
went to sleep in his car while smoking a cigarette, which ignited the
seats in S's car and touched off a general conflagration that
burned P's garage to the ground. S's body was found
in his car in the smoldering remains of the garage. At trial, P
offers evidence of three previous fires caused by S's smoking
and falling asleep.

Is such evidence relevant? Is it admissible? Is it evidence of habit
or character?